Philips v. Department of the Navy

CourtDistrict Court, District of Columbia
DecidedJuly 15, 2020
DocketCivil Action No. 2019-0650
StatusPublished

This text of Philips v. Department of the Navy (Philips v. Department of the Navy) is published on Counsel Stack Legal Research, covering District Court, District of Columbia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Philips v. Department of the Navy, (D.D.C. 2020).

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

TARIK PHILIPS,

Plaintiff,

v. Case No. 1:19-cv-00650 (TNM)

DEPARTMENT OF THE NAVY,

Defendant.

MEMORANDUM OPINION

Tarik Philips, proceeding pro se, submitted a request under the Freedom of

Information Act (“FOIA”) to the Department of the Navy, asking for medical and

investigative records that he believes will help overturn his murder conviction. He

challenges the Navy’s response, alleging that its search for responsive documents was

inadequate and that its withholdings were improper. 1 Because the Navy has fully complied

with its obligations under FOIA, the Court will grant its motion for summary judgment.

I.

In 2006, Philips was convicted by a New York jury of second-degree murder, assault, and

related charges in connection with a shooting incident. See People v. Philips, 992 N.Y.S.2d 104

(N.Y. App. Div. 2014). Nonetheless, he maintains his innocence. Marx Decl. Exs. at 10, ECF

No. 21-3. 2

As relevant here, Philips disputes the testimony of a key witness in his trial, Jody Brown,

1 Under the screening provisions of 28 U.S.C. § 1915A, all individually named defendants were dismissed as improper parties to this FOIA suit. See Order (Apr. 26, 2019), ECF No. 5. 2 All page citations refer to the page numbers that the CM/ECF system generates. who witnessed the shooting and sustained injuries. Id. at 29, 31. According to Philips, Brown’s

credibility was the “linchpin of the prosecution[’s] case.” Id. at 31. Because Brown was in the

military, a medical review board interviewed him about the incident and his injuries. Id. at 29.

Philips believes there are discrepancies between Brown’s statements to the Navy’s review board

and Brown’s testimony at trial. Id. at 31. Philips also claims that the Brooklyn District

Attorney’s Office conspired with the Navy to secure Brown an honorable discharge in exchange

for his testimony against Philips. Pl.’s Opp’n at 13–14, ECF No. 26-1. 3

In April 2018, Philips sent a FOIA request to the Navy, writing:

I request the Medical Evaluation Board records in relation to the medical retirement of Jody Brown. I’m specifically requesting access to and copies of the above subject matter [Medical Evaluation Board Case]. These documents are related to an ongoing criminal litigation and these documents can possibly serve to exonerate an innocent man from prison. This FOIA request is not limited to medical board records pertaining to the answers and questions brought out through this proceeding. It is also inclusive to the letters of support produced before this boards [sic] review that was [sic] written by Assistant District Attorney Robert Walsh or any officer of the court.

Marx Decl. Exs. at 10. The Navy initially denied Philips’s request because it provided

insufficient identifying information about Brown. Id. at 13. When Philips supplied additional

information in his appeal, the Navy remanded the case so that “the amplifying information”

could “facilitate a more targeted search.” Id. at 22–23.

After performing a search, the Navy informed Philips that “a Physical Evaluation Board

file does exist for a Mr. Jody Brown,” but withheld it under FOIA Exemption 6. Id. at 25. In

appealing that decision, Philips asserted a public interest in disclosing the file, suggesting that

3 Philips’s opposition brief is at ECF No. 25, but that version is missing two pages. The Navy was served with the full brief, and it attached this complete version to its reply brief, at ECF No. 26-1. The Court’s citations to Philips’s opposition brief are references to ECF No. 26-1. 2 Brown’s statements to the “Medical Evaluation Board” contradicted his testimony at Philips’s

criminal trial. Id. at 29–32. But the Navy rejected Philips’s appeal, maintaining that the “total

withholding” of Brown’s medical file was proper under Exemption 6. Id. at 40–41. Philips then

sued here.

During this litigation, the Navy located Brown’s Physical Evaluation Board (“PEB”) file,

which includes the requested Medical Evaluation Board file. See Marx Decl. ¶¶ 9–11 & n.1. In

reviewing this file, the Navy “identified at least one document that required consultation with the

Naval Criminal Investigative Service (‘NCIS’)” and asked NCIS to search for responsive

records. Id. ¶ 11. NCIS searched its records database and located “a 67-page NCIS

Investigation File” related to a closed investigation. Id.

In September 2019, the Navy released the NCIS file to Philips with “the names of

investigators, witnesses, victims, and other third parties” redacted under FOIA Exemptions 6 and

7(C). Id. ¶ 17. Four pages “that pertained to another defendant implicated in the incident which

injured [Brown]” were withheld in full. Id. The Navy also released a previously withheld

portion of the PEB file: a six-page document “reflecting the command investigation into the

shooting incident in question,” with third-party information withheld under the same exemptions.

Id. ¶ 12. It withheld the remainder of Brown’s PEB file under Exemption 6. Id. ¶ 13. See

generally Marx Decl. Exs. at 114–20 (Vaughn Index). The Navy is “unaware of any other

locations where responsive documents might be found.” Marx Decl. ¶ 11.

The Navy’s motion for summary judgment, ECF No. 21, is now ripe.

II.

FOIA requires federal agencies to “disclose information to the public upon reasonable

request unless the records at issue fall within specifically delineated exemptions.” Judicial

3 Watch, Inc. v. FBI, 522 F.3d 364, 366 (D.C. Cir. 2008). A district court reviews the record de

novo, 5 U.S.C. § 552(a)(4)(B), and it views the facts and draws all inferences “in the light most

favorable to the requester,” Weisberg v. DOJ (“Weisberg II”), 745 F.2d 1476, 1485 (D.C. Cir.

1984).

The “vast majority” of FOIA cases can be decided on motions for summary judgment.

Brayton v. Office of U.S. Trade Rep., 641 F.3d 521, 527 (D.C. Cir. 2011). To prevail, the

movant agency must prove through nonconclusory affidavits that no material facts are in

dispute, see Fed. R. Civ. P. 56(a), and that each responsive record has been produced to the

requestor, is unidentifiable, or is exempt from disclosure. See Weisberg v. DOJ (“Weisberg

I”), 627 F.2d 365, 368 (D.C. Cir. 1980).

The agency has the burden to demonstrate that any withheld information falls into one

of FOIA’s exemptions. 5 U.S.C. § 552(a)(4)(B); see NRDC v. Nuclear Reg. Comm’n, 216

F.3d 1180, 1190 (D.C. Cir. 2000). “The justification for invoking a FOIA exemption is

sufficient if it appears logical or plausible.” Murphy v. EOUSA, 789 F.3d 204, 209 (D.C. Cir.

2015) (cleaned up).

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